UNOPPOSED MOTION OF DEFENDANT JEFFERSON MORRILL TO MODIFY STANDARD CONDITION OF PROBATION SUPERVISION

LORNA G. SCHOFIELD, District Judge.

COMES NOW the Defendant, Jefferson Morrill, by and through his undersigned counsel, and hereby respectfully requests that the Court enter an order modifying Standard Condition of Supervision No. 3 which precludes him from "leav[ing] the federal judicial district where [he is] authorized to reside [Middle District of Tennessee] without first getting permission from the court or the probation officer" to permit Mr. Morrill to travel to the Sports Licensing & Tailgate Show in Las Vegas, Nevada, between the dates of January 14 through 18, 2020. (Docket Entry 28 at p. 4). In support hereof, Defendant states as follows:

1. On November 12, 2019, this Court sentenced Mr. Morrill to a one-year term of probation as a result of his conviction for trafficking in counterfeit goods, in violation of 18 U.S.C. § 2320. (Docket Entry 28, Judgment In A Criminal Case). The judgment contains Standard Conditions of Supervision. Id. at p.4. Standard Condition No. 3 precludes him from "leav[ing] the federal judicial district where [he is] authorized to reside [Middle District of Tennessee] without first getting permission from the court or the probation officer." Id.

2. Since Mr. Morrill resides in the Middle District of Tennessee, Mr. Morrill's probation supervision was administratively transferred to the U.S. Probation Office for the Middle District of Tennessee. Mr. Morrill is being supervised by MDTN U.S. Probation Officer Montranese Vinson.

3. As disclosed in Mr. Morrill's Presentence Report, Mr. Morrill owns and operates Rochester Sports, an autographed sports memorabilia company, which sells legitimate, legal, signed sports merchandise. Mr. Morrill needs to attend a sports licensing show in Las Vegas between the dates of January 14 and January 18, 2020. Appended hereto as Attachment 1 is an excerpt of a brochure which promotes the Sports Licensing & Tailgate Show which will be taking place at the Mandalay Bay Convention Center in Las Vegas between January 16 and 18, 2020. (Mr. Morrill needs to travel to Las Vegas on 1/15/2020.) This is the biggest sports memorabilia show in the United States and Mr. Morrill needs to attend in person to meet with vendors and companies to purchase legitimate items upon which real autograph signatures can be affixed and resold.

4. Undersigned counsel has met personally with MDTN Probation Officer Vinson who has authorized counsel to report that Mr. Morrill has been compliant with his probation supervision in all respects and Ms. Vinson is not opposed to this travel request as long as the Court approves the travel consistent with Standard Condition No. 3.

5. Assistant United States Attorney Daniel Nessim has authorized undersigned counsel to report that the government does not oppose this motion.

WHEREFORE, based on the foregoing, Defendant Morrill respectfully requests that the Court enter an order modifying Standard Condition of Supervision No. 3 which precludes him from "leav[ing] the federal judicial district where [he is] authorized to reside [Middle District of Tennessee] without first getting permission from the court or the probation officer" to permit Mr. Morrill to travel to the Sports Licensing & Tailgate Show in Las Vegas, Nevada, between the dates of January 14 through 18, 2020.

Application Granted. The Clerk of the Court is directed to terminate the letter motion at docket number 33.